In the United Nations General Assembly and other international forums, China has frequently argued that national and multilateral export control measures infringe on the right of states—particularly developing states—to benefit from international cooperation in science and technology. In particular, it has called out the ‘abuse’ of export controls by some governments to achieve strategic or economic ends that have little to do with non-proliferation.
At the same time, since 2020 China has strengthened its own export control regime and used it in ways that are retaliatory and coercive, to pursue unambiguously geopoliticalobjectives and to respond to actions taken by other governments, primarily the United States.
This backgrounder examines China’s recent rhetoric and action in relation to export controls and explores the rationale behind them.
The aims of export controls
The primary aim of export controls—policy instruments used to regulate and oversee the trade in military and dual-use items—is to prevent the proliferation of weapons of mass destruction (WMD) and other sensitive items that may represent a threat to international peace and security. Their scope is shaped by the four multilateral export control regimes—the Australia Group, the Missile Technology Control Regime, the Nuclear Suppliers Group (NSG) and the Wassenaar Arrangement—which establish control lists and guidelines that function as de facto international standards. However, none of these control lists or guidelines is legally binding, and states retain flexibility in how they implement them at the national level, including being able to control items that are not on the agreed lists.
In reality, states also use export controls to pursue and balance several, often competing objectives, beyond non-proliferation. The most prominent example has been the USA, which openly states that it uses export controls to safeguard national security and promote economic interests as well as to sustain ‘US strategic technology leadership’, including through unilateral controls. As geopolitical competition intensifies, maintaining a balance among these objectives is becoming increasingly difficult. For instance, the European Union (EU) has developed an economic security strategy that highlights the need to address external economic threats and to reduce its strategic dependencies, indicating export controls as one of the policy instruments at its disposal.
While all states face the challenge of balancing these numerous objectives, what differs is how they manage this challenge and how clearly they articulate their approach. China’s evolving export control approach reflects such tension.
Until the early 2000s, China was viewed by Western states as a proliferator of sensitive technologies. Since then, it has made efforts to build a more comprehensive export control system and to align it with key international regimes. With improved domestic export control regulations and relatively stable relations with the USA, China was able to join the NSG in 2004 and has also sought membership of the other regimes.
The steps that China has taken since 2020 to further reinforce its export control system and bring it closer to international standards mark, to some extent, the culmination of this evolving approach. At the same time, it set the stage for China to use export controls to advance its national interests, to respond to perceived security threats and to manage geopolitical competition, including through economic coercion.
Recent developments in China’s export control system
Since 2020, China has taken significant steps to strengthen and consolidate its national export control system for dual-use items—items with both civilian and potential military uses. A milestone in this process was the adoption of the 2020 Export Control Law (ECL; see figure 1), an overarching framework for regulating the exports of ‘dual-use items, military products, nuclear and other goods, technologies, services related to safeguarding national security and interest or performing non-proliferation and other international obligations’. A number of subsequent measures flesh out the provisions of the ECL, particularly the 2024 Regulations of Export Control of Dual-Use Items (Dual-Use Regulations).
These measures sought to consolidateexisting control lists and a fragmented regulatory landscape, to clarify licensing procedures, and to define the implementation and compliance responsibilities of the Ministry of Commerce (MOFCOM), the main licensing authority, and exporters. They also increased alignment with international standards, for instance by making the national control lists more granularand closer to those of the Wassenaar Arrangement and the other regimes. At the same time, they also provided China with tools to promote its national and security interests, including by means of enabling countermeasures to external threats.
Particularly significant in this regard is the assertion that Chinese export control legislation applies extra-territorially, meaning that foreign entities re-exporting items of Chinese origin or items that incorporate Chinese dual-use items are also subject to its provisions. The USA was the only other country that had done this, and it had often been a source of tension, including with US allies in Europe, and also attracted strong criticism from China.
China has also made extensive use of unilateral export controls. Since 2023, citing a combination of national security interestsand international non-proliferation obligations, China has imposed export controls on an expanding list of critical materials,including rare earths, along with related production technologies. Some of the control lists of the multilateral export control regimes include certain critical minerals and rare earths, on the basis of specific technical specifications, including purity thresholds. China’s export controls on certain critical materials differ from and go beyond the multilateral regimes’ technical specifications. They also extend to critical materials that are not generally considered to be dual-use. As such, they are far broader in scope than what most other states have sought to control through their dual-use export control systems.
Since 2020, China has also introduced different forms of end user-based export control, mirroring elements of the US export control system. These controls include restrictions on exports of dual-use items to entities on the Chinese export control list that are deemed to engage in activities that endanger China’s national security or to violate export control regulations. The Dual-Use Regulations created a ‘watch list’, analogous to the USA’s Unverified List, that identifies entities that have failed to cooperate with Chinese end-user verification procedures, making it more difficult for them to do business in China. Finally, China also established the Unreliable Entity List (UEL) in 2020, which can be used to prohibit or restrict listed entities from ‘engaging in import and export activities related to China’, making it similar to the US government’s Entity List.
Chinese export control measures should be seen in the context of a much wider legislative frameworkproviding China with a legal toolkit for retaliation against economic coercion—but that can also be used for similarly coercive purposes. For instance, the UEL, which serves a more explicit anti-coercion role, is grounded in the revised 1994 Foreign Trade Law—which itself can be used to impose trade bans and restrictions on foreign entities deemed to ‘endanger’ China’s sovereignty, security or development interests.
Along with the Foreign Trade Law, this framework includes instruments like the 2021 Anti-Foreign Sanctions Law, which can restrict trade with designated individuals or entities on national security grounds, and other tools to regulate, prohibit or restrict the trade in sensitive civilian technologies deemedessential for national security. In April 2026, China also adopted a new regulation to protect the security of its industrial and supply chains, which includes the possibility of using export controls as countermeasures against foreign entities.
The coercive and retaliatory effects of Chinese export controls
The potential to use export controls as tools to retaliate and manage competition became increasingly evident in China’s response to US technology transfer restrictions imposed by the USA during the years of President Joe Biden’s administration, particularly after 2022, and, since 2025, to trade tariffs imposed by President Donald J. Trump. Then in early 2026, China also imposed new export controls as part of escalating tensions with Japan, following remarks on Taiwan made by Japanese Prime Minister Sanae Takaichi. This move has been interpreted as not only punishing Japan but also a warning to other countries for their position on Taiwan. It has also been characterized as ‘coercive diplomacy’ to achieve broader military and strategic objectives.
This month, China added seven EU entities to its control list over arms sales to Taiwan, just one day after the EU announced its latest round of sanctions against Russia, targeting entities in third countries, including China, for providing dual-use and military items to Russia. These listings also have extra-territorial reach, as they prohibit foreign entities from transferring items originating in China to the listed companies.
China’s retaliation against both Japan and the USA focused on using export control measures to leverage global supply chain dependencies on China’s critical materials sector—in which it maintains de-facto monopolies.
In most cases, the export control measures China has imposed concerning critical materials have entailed export licensing requirements rather than outright bans and they have not explicitly targeted specific countries. The main exceptions were related to the USA and Japan.
MOFCOM announced an explicit prohibition of exports of gallium, germanium, antimony and superhard materials to the USA and of transfers of dual-use items to US military end-users in December 2024.At the moment of highest tension in the trade confrontation with the USA, in October 2025, China further escalated its response by making the export of certain critical materials subject to extra-territorial controls, although this measure was suspended for a year shortly afterwards, following an agreement between Trump and Chinese President Xi Jinping. In January 2026, China placed a ban on exports of all dual-use items and critical materials to Japanese military end-users.
China’s export control measures targeting both the USA and Japan also included extensive end user-based controls. In 2023 Lockheed Martin Corporation and Raytheon Missiles & Defense were the first companies to be added to the UEL. Since then, China has added more US companies. In 2025 China designated over 50 entities under the UEL, compared to only four such designations in 2024. In 2026, China placed 20 Japanese entities on its watch list and another 20 companies on its control list. The inclusion of Japanese companies in the Chinese export control list also has explicit extra-territorial application.
Other states besides those explicitly targeted have also felt the effects of China’s expanded export controls. By subjecting such a broad list of items to its licensing procedures, China’s export controls and restrictions generated compliance costs and uncertainty for all recipients of Chinese exports of controlled items. This set of problems was exacerbated by the time necessary to roll out a licensing system to implement such expanded controls. In a 2025 survey, European importers noted long approval times and a lack of clarity in the Chinese licensing process. Affected importers have also expressed concern about the amount of information required by MOFCOM as part of the licence application, for example on how the materials imported would be used, ‘product images and even photos of production lines’. In some cases, China’s licensing requirements have constituted a de-facto ban.
At the end of 2025, China announced that it had started granting general licences for the export of rare earths. While statements by the European Commission confirmed that some European companies had obtained such licences, there were also reports suggesting selective implementation of controls.
China’s approach to export controls in multilateral forums
The most recent and most significant developments in the Chinese export control system coincided with Chinese initiatives in the UN General Assembly criticizing national and multilateral export controls.
In 2021, 2022 and 2024, the UN General Assembly adopted resolutions submitted and co-sponsored by China on ‘Promoting international cooperation on peaceful uses in the context of international security’. The three resolutions note that national and multilateral export control measures impose ‘undue restrictions’ that infringe on states’ right, particularly those of developing states, to benefit from international cooperation in science and technology for peaceful uses, as recognized by the 1972 Biological and Toxin Weapons Convention, the 1993 Chemical Weapons Convention and the 1968 Nuclear Non-Proliferation Treaty.
The resolutions have been interpreted as critical towards the export control regimes. In 2022, China’s messaging around the resolutions went so far as to leave open the possibility of creating alternative arrangements to the regimes. However, the 2024 resolution is more moderate than its predecessors, as formulating ‘guiding principles as appropriate’ is the only step states are called to take to implement the resolution.
Divergent views between exporting and importing states over how to strike the correct balance between the right to access technologies for ‘peaceful uses’ and the use of export controls for non-proliferation have a long history. States from the Non-Aligned Movement have repeatedly complainedthat trade restrictions hinder their right to access technology for peaceful uses. China has often shared similar views, criticizing other countries’ attempts to ‘stretch the national security concept’ and to use export controls as a geopolitical tool that undermines international cooperation and trade. China’s 2025 white paperon arms control, disarmament and non-proliferation reiterates these points.
China’s initiatives in the UN General Assembly and other platforms to criticize the ‘abuse’ of export controls and the regimes can partly be seen as a response to US export control measures. At the same time, China remains part of the NSG and ‘actively participates’ in discussions to revise and improve its control lists and guidelines. China also maintains contact with the other regimes. Further, in the 2025 white paper China stresses its active role in ‘participating in the building of international non-proliferation and export control system’ and its importance in addressing WMD proliferation.
China’s domestic framing
As the developments described above show, China’s position on national and multilateral export controls can appear inconsistent. However, the evolution of China’s export control system is not viewed domestically as contradicting its multilateral obligations to non-proliferation and commitment to uphold the right to technology for peaceful uses.
Rather, export controls are framed as being consistent with safeguarding national security in an evolving international environment. For instance, the decision to impose restrictions on Japan has been justified by MOFCOM as an attempt to ‘curb Japan’s attempts at “remilitarization” and possession of nuclear weapons’. Similarly, export controls on critical minerals have been presented as necessary to prevent their use in foreign military applications that could pose ‘significant damage or potential threats to China’s national security and interests’. This line of argument is not new in China.
Back in 2019 there were already active discussions on concerns over the ‘use of China’s rare earth resources to manufacture products that are then used to contain and suppress China’s development’. Since then, the way China has framed its foreign trade and export control regulations clearly indicates how these tools are gradually turning into a core means of strategic competition and are becoming more closely aligned with China’s foreign policy objectives.
Export controls are also increasingly regarded as a means to challenge an international order that China sees as being dominated by the West. This view of the international order aligns with key principles guiding China’s governance approach at the international level that are outlined in the Global Governance Initiative (GGI), which was introduced by China in October 2025. The GGI calls for ‘the building of a more just and equitable global governance system’. However, what this means is open to interpretation. In practice, it may involve undermining what China views as the dominance of the USA and its allies while reshaping the global governance system to align with Chinese preferences.
Conclusions
China is certainly not the only state increasingly using export controls unilaterally and coercively to advance its national interests and to manage strategic competition. In this context, the role of export controls as tools of multilateral cooperation on non-proliferation is becoming difficult to sustain and is slipping down the agenda.
The recent steps that China has taken to expand its export control system and the ways it has used it both reflect and exacerbate this trend. The scope, coverage and reach of China’s export controls go far beyond the standards outlined in the multilateral export control regimes and their impact is amplified by global reliance on Chinese exports in key sectors. China’s evolving export control toolkit can therefore be effectively used for regulatory purposes but also as an instrument of coercion or retaliation, particularly by leveraging supply chain dependencies.
At the same time, in international forums China remains one of the most vocal critics of the ‘abuse’ of export controls in pursuit of national security objectives and of controls that prevent transfers of technology for peaceful purposes. To many external observers, this equates to a disconnect between what China is calling for on the international stage and what it is doing at the national level.
As China continues to develop its export control system, states in the rest of the world should ask China for greater clarity on its views regarding multilateral export controls and how to balance non-proliferation with equitable access to technology and use of unilateral controls. This clarity would provide a more concrete basis for constructive engagement and discussions with states in the context of the multilateral export control regimes, the UN General Assembly and, possibly, other forums.
With support from the Australia Department of Defence, SIPRI is conducting a project examining China’s export controls and their implications for the multilateral export control regimes that underpin non-proliferation efforts as well as for Australia’s National Defence Strategy.
ABOUT THE AUTHOR(S)
Giovanna Maletta is a Senior Researcher in the SIPRI Dual-Use and Arms Trade Control Programme.
Fei Su is a Senior Researcher in the SIPRI China and Asia Security Programme.
In the United Nations General Assembly and other international forums, China has frequently argued that national and multilateral export control measures infringe on the right of states—particularly developing states—to benefit from international cooperation in science and technology. In particular, it has called out the ‘abuse’ of export controls by some governments to achieve strategic or economic ends that have little to do with non-proliferation.
At the same time, since 2020 China has strengthened its own export control regime and used it in ways that are retaliatory and coercive, to pursue unambiguously geopolitical objectives and to respond to actions taken by other governments, primarily the United States.
This backgrounder examines China’s recent rhetoric and action in relation to export controls and explores the rationale behind them.
The aims of export controls
The primary aim of export controls—policy instruments used to regulate and oversee the trade in military and dual-use items—is to prevent the proliferation of weapons of mass destruction (WMD) and other sensitive items that may represent a threat to international peace and security. Their scope is shaped by the four multilateral export control regimes—the Australia Group, the Missile Technology Control Regime, the Nuclear Suppliers Group (NSG) and the Wassenaar Arrangement—which establish control lists and guidelines that function as de facto international standards. However, none of these control lists or guidelines is legally binding, and states retain flexibility in how they implement them at the national level, including being able to control items that are not on the agreed lists.
In reality, states also use export controls to pursue and balance several, often competing objectives, beyond non-proliferation. The most prominent example has been the USA, which openly states that it uses export controls to safeguard national security and promote economic interests as well as to sustain ‘US strategic technology leadership’, including through unilateral controls. As geopolitical competition intensifies, maintaining a balance among these objectives is becoming increasingly difficult. For instance, the European Union (EU) has developed an economic security strategy that highlights the need to address external economic threats and to reduce its strategic dependencies, indicating export controls as one of the policy instruments at its disposal.
While all states face the challenge of balancing these numerous objectives, what differs is how they manage this challenge and how clearly they articulate their approach. China’s evolving export control approach reflects such tension.
Until the early 2000s, China was viewed by Western states as a proliferator of sensitive technologies. Since then, it has made efforts to build a more comprehensive export control system and to align it with key international regimes. With improved domestic export control regulations and relatively stable relations with the USA, China was able to join the NSG in 2004 and has also sought membership of the other regimes.
The steps that China has taken since 2020 to further reinforce its export control system and bring it closer to international standards mark, to some extent, the culmination of this evolving approach. At the same time, it set the stage for China to use export controls to advance its national interests, to respond to perceived security threats and to manage geopolitical competition, including through economic coercion.
Recent developments in China’s export control system
Since 2020, China has taken significant steps to strengthen and consolidate its national export control system for dual-use items—items with both civilian and potential military uses. A milestone in this process was the adoption of the 2020 Export Control Law (ECL; see figure 1), an overarching framework for regulating the exports of ‘dual-use items, military products, nuclear and other goods, technologies, services related to safeguarding national security and interest or performing non-proliferation and other international obligations’. A number of subsequent measures flesh out the provisions of the ECL, particularly the 2024 Regulations of Export Control of Dual-Use Items (Dual-Use Regulations).
These measures sought to consolidate existing control lists and a fragmented regulatory landscape, to clarify licensing procedures, and to define the implementation and compliance responsibilities of the Ministry of Commerce (MOFCOM), the main licensing authority, and exporters. They also increased alignment with international standards, for instance by making the national control lists more granular and closer to those of the Wassenaar Arrangement and the other regimes. At the same time, they also provided China with tools to promote its national and security interests, including by means of enabling countermeasures to external threats.
Particularly significant in this regard is the assertion that Chinese export control legislation applies extra-territorially, meaning that foreign entities re-exporting items of Chinese origin or items that incorporate Chinese dual-use items are also subject to its provisions. The USA was the only other country that had done this, and it had often been a source of tension, including with US allies in Europe, and also attracted strong criticism from China.
China has also made extensive use of unilateral export controls. Since 2023, citing a combination of national security interests and international non-proliferation obligations, China has imposed export controls on an expanding list of critical materials, including rare earths, along with related production technologies. Some of the control lists of the multilateral export control regimes include certain critical minerals and rare earths, on the basis of specific technical specifications, including purity thresholds. China’s export controls on certain critical materials differ from and go beyond the multilateral regimes’ technical specifications. They also extend to critical materials that are not generally considered to be dual-use. As such, they are far broader in scope than what most other states have sought to control through their dual-use export control systems.
Since 2020, China has also introduced different forms of end user-based export control, mirroring elements of the US export control system. These controls include restrictions on exports of dual-use items to entities on the Chinese export control list that are deemed to engage in activities that endanger China’s national security or to violate export control regulations. The Dual-Use Regulations created a ‘watch list’, analogous to the USA’s Unverified List, that identifies entities that have failed to cooperate with Chinese end-user verification procedures, making it more difficult for them to do business in China. Finally, China also established the Unreliable Entity List (UEL) in 2020, which can be used to prohibit or restrict listed entities from ‘engaging in import and export activities related to China’, making it similar to the US government’s Entity List.
Chinese export control measures should be seen in the context of a much wider legislative framework providing China with a legal toolkit for retaliation against economic coercion—but that can also be used for similarly coercive purposes. For instance, the UEL, which serves a more explicit anti-coercion role, is grounded in the revised 1994 Foreign Trade Law—which itself can be used to impose trade bans and restrictions on foreign entities deemed to ‘endanger’ China’s sovereignty, security or development interests.
Along with the Foreign Trade Law, this framework includes instruments like the 2021 Anti-Foreign Sanctions Law, which can restrict trade with designated individuals or entities on national security grounds, and other tools to regulate, prohibit or restrict the trade in sensitive civilian technologies deemed essential for national security. In April 2026, China also adopted a new regulation to protect the security of its industrial and supply chains, which includes the possibility of using export controls as countermeasures against foreign entities.
The coercive and retaliatory effects of Chinese export controls
The potential to use export controls as tools to retaliate and manage competition became increasingly evident in China’s response to US technology transfer restrictions imposed by the USA during the years of President Joe Biden’s administration, particularly after 2022, and, since 2025, to trade tariffs imposed by President Donald J. Trump. Then in early 2026, China also imposed new export controls as part of escalating tensions with Japan, following remarks on Taiwan made by Japanese Prime Minister Sanae Takaichi. This move has been interpreted as not only punishing Japan but also a warning to other countries for their position on Taiwan. It has also been characterized as ‘coercive diplomacy’ to achieve broader military and strategic objectives.
This month, China added seven EU entities to its control list over arms sales to Taiwan, just one day after the EU announced its latest round of sanctions against Russia, targeting entities in third countries, including China, for providing dual-use and military items to Russia. These listings also have extra-territorial reach, as they prohibit foreign entities from transferring items originating in China to the listed companies.
China’s retaliation against both Japan and the USA focused on using export control measures to leverage global supply chain dependencies on China’s critical materials sector—in which it maintains de-facto monopolies.
In most cases, the export control measures China has imposed concerning critical materials have entailed export licensing requirements rather than outright bans and they have not explicitly targeted specific countries. The main exceptions were related to the USA and Japan.
MOFCOM announced an explicit prohibition of exports of gallium, germanium, antimony and superhard materials to the USA and of transfers of dual-use items to US military end-users in December 2024. At the moment of highest tension in the trade confrontation with the USA, in October 2025, China further escalated its response by making the export of certain critical materials subject to extra-territorial controls, although this measure was suspended for a year shortly afterwards, following an agreement between Trump and Chinese President Xi Jinping. In January 2026, China placed a ban on exports of all dual-use items and critical materials to Japanese military end-users.
China’s export control measures targeting both the USA and Japan also included extensive end user-based controls. In 2023 Lockheed Martin Corporation and Raytheon Missiles & Defense were the first companies to be added to the UEL. Since then, China has added more US companies. In 2025 China designated over 50 entities under the UEL, compared to only four such designations in 2024. In 2026, China placed 20 Japanese entities on its watch list and another 20 companies on its control list. The inclusion of Japanese companies in the Chinese export control list also has explicit extra-territorial application.
Other states besides those explicitly targeted have also felt the effects of China’s expanded export controls. By subjecting such a broad list of items to its licensing procedures, China’s export controls and restrictions generated compliance costs and uncertainty for all recipients of Chinese exports of controlled items. This set of problems was exacerbated by the time necessary to roll out a licensing system to implement such expanded controls. In a 2025 survey, European importers noted long approval times and a lack of clarity in the Chinese licensing process. Affected importers have also expressed concern about the amount of information required by MOFCOM as part of the licence application, for example on how the materials imported would be used, ‘product images and even photos of production lines’. In some cases, China’s licensing requirements have constituted a de-facto ban.
At the end of 2025, China announced that it had started granting general licences for the export of rare earths. While statements by the European Commission confirmed that some European companies had obtained such licences, there were also reports suggesting selective implementation of controls.
China’s approach to export controls in multilateral forums
The most recent and most significant developments in the Chinese export control system coincided with Chinese initiatives in the UN General Assembly criticizing national and multilateral export controls.
In 2021, 2022 and 2024, the UN General Assembly adopted resolutions submitted and co-sponsored by China on ‘Promoting international cooperation on peaceful uses in the context of international security’. The three resolutions note that national and multilateral export control measures impose ‘undue restrictions’ that infringe on states’ right, particularly those of developing states, to benefit from international cooperation in science and technology for peaceful uses, as recognized by the 1972 Biological and Toxin Weapons Convention, the 1993 Chemical Weapons Convention and the 1968 Nuclear Non-Proliferation Treaty.
The resolutions have been interpreted as critical towards the export control regimes. In 2022, China’s messaging around the resolutions went so far as to leave open the possibility of creating alternative arrangements to the regimes. However, the 2024 resolution is more moderate than its predecessors, as formulating ‘guiding principles as appropriate’ is the only step states are called to take to implement the resolution.
Divergent views between exporting and importing states over how to strike the correct balance between the right to access technologies for ‘peaceful uses’ and the use of export controls for non-proliferation have a long history. States from the Non-Aligned Movement have repeatedly complained that trade restrictions hinder their right to access technology for peaceful uses. China has often shared similar views, criticizing other countries’ attempts to ‘stretch the national security concept’ and to use export controls as a geopolitical tool that undermines international cooperation and trade. China’s 2025 white paper on arms control, disarmament and non-proliferation reiterates these points.
China’s initiatives in the UN General Assembly and other platforms to criticize the ‘abuse’ of export controls and the regimes can partly be seen as a response to US export control measures. At the same time, China remains part of the NSG and ‘actively participates’ in discussions to revise and improve its control lists and guidelines. China also maintains contact with the other regimes. Further, in the 2025 white paper China stresses its active role in ‘participating in the building of international non-proliferation and export control system’ and its importance in addressing WMD proliferation.
China’s domestic framing
As the developments described above show, China’s position on national and multilateral export controls can appear inconsistent. However, the evolution of China’s export control system is not viewed domestically as contradicting its multilateral obligations to non-proliferation and commitment to uphold the right to technology for peaceful uses.
Rather, export controls are framed as being consistent with safeguarding national security in an evolving international environment. For instance, the decision to impose restrictions on Japan has been justified by MOFCOM as an attempt to ‘curb Japan’s attempts at “remilitarization” and possession of nuclear weapons’. Similarly, export controls on critical minerals have been presented as necessary to prevent their use in foreign military applications that could pose ‘significant damage or potential threats to China’s national security and interests’. This line of argument is not new in China.
Back in 2019 there were already active discussions on concerns over the ‘use of China’s rare earth resources to manufacture products that are then used to contain and suppress China’s development’. Since then, the way China has framed its foreign trade and export control regulations clearly indicates how these tools are gradually turning into a core means of strategic competition and are becoming more closely aligned with China’s foreign policy objectives.
Export controls are also increasingly regarded as a means to challenge an international order that China sees as being dominated by the West. This view of the international order aligns with key principles guiding China’s governance approach at the international level that are outlined in the Global Governance Initiative (GGI), which was introduced by China in October 2025. The GGI calls for ‘the building of a more just and equitable global governance system’. However, what this means is open to interpretation. In practice, it may involve undermining what China views as the dominance of the USA and its allies while reshaping the global governance system to align with Chinese preferences.
Conclusions
China is certainly not the only state increasingly using export controls unilaterally and coercively to advance its national interests and to manage strategic competition. In this context, the role of export controls as tools of multilateral cooperation on non-proliferation is becoming difficult to sustain and is slipping down the agenda.
The recent steps that China has taken to expand its export control system and the ways it has used it both reflect and exacerbate this trend. The scope, coverage and reach of China’s export controls go far beyond the standards outlined in the multilateral export control regimes and their impact is amplified by global reliance on Chinese exports in key sectors. China’s evolving export control toolkit can therefore be effectively used for regulatory purposes but also as an instrument of coercion or retaliation, particularly by leveraging supply chain dependencies.
At the same time, in international forums China remains one of the most vocal critics of the ‘abuse’ of export controls in pursuit of national security objectives and of controls that prevent transfers of technology for peaceful purposes. To many external observers, this equates to a disconnect between what China is calling for on the international stage and what it is doing at the national level.
As China continues to develop its export control system, states in the rest of the world should ask China for greater clarity on its views regarding multilateral export controls and how to balance non-proliferation with equitable access to technology and use of unilateral controls. This clarity would provide a more concrete basis for constructive engagement and discussions with states in the context of the multilateral export control regimes, the UN General Assembly and, possibly, other forums.
With support from the Australia Department of Defence, SIPRI is conducting a project examining China’s export controls and their implications for the multilateral export control regimes that underpin non-proliferation efforts as well as for Australia’s National Defence Strategy.
ABOUT THE AUTHOR(S)